TC09528 - [2025] UKFTT 00564 (TC)

Ingliston has not raised any procedural or arithmetical challenges in this case. The sole issue in dispute is whether the supplies qualified for the reduced rate of VAT.

At the outset of the hearing, Mr Winter queried whether a small portion of Ingliston’s supplies might be subject to a different VAT treatment from the main supplies of driving experiences. If so, HMRC were willing to give Ingliston the opportunity to quantify these supplies: on the basis, we inferred, that if we were to dismiss the main appeal, this might improve Ingliston’s VAT position in relation to these separate supplies.

Mr Hayes told us that he was happy to “bundle up” the supplies and took the view that there was only one question in dispute, namely whether Ingliston’s supplies qualified for the reduced rate of VAT.

We understood from this that neither party wished to submit that Ingliston made different supplies with different VAT treatments. We also had no evidence that would enable us to quantify any such different supplies. We have therefore proceeded on the basis that Ingliston made only one type of supply, and that it is our task to determine the VAT rating of that supply.

We have carefully considered the submissions and evidence of both parties, but have not found it necessary to refer to every argument and authority that was put to us, nor to describe every part of the evidence.